Sunamerica Asset Management, Llc

Allegations: IN DECEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $1,500.00 ADMINISTRATIVE FINE TO THE MARYLAND INSURANCE ADMINISTRATION AS THE RESULT OF A REGULATORY COMPLAINT, BASED ON THE ADMINISTRATION'S FINDING THAT THE COMPANY ALLEGEDLY COLLECTED BOTH PREMIUMS AND POLICY DIVIDENDS ON THE POLICIES OF TWO INSUREDS, AND ALLEGEDLY FAILED TO APPLY THOSE DIVIDENDS TO PAY THE POLICIES' PREMIUMS, RESULTING IN ONE OF THOSE POLICIES LAPSING. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $1,500.00 PAID ON 12/04/2021. THE FULL FINE AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED. Summary: IN DECEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $1,500.00 ADMINISTRATIVE FINE TO THE MARYLAND INSURANCE ADMINISTRATION AS THE RESULT OF A REGULATORY COMPLAINT, BASED ON THE ADMINISTRATION'S FINDING THAT THE COMPANY ALLEGEDLY COLLECTED BOTH PREMIUMS AND POLICY DIVIDENDS ON THE POLICIES OF TWO INSUREDS, AND ALLEGEDLY FAILED TO APPLY THOSE DIVIDENDS TO PAY THE POLICIES' PREMIUMS, RESULTING IN ONE OF THOSE POLICIES LAPSING.

Allegations: AMERICAN INTERNATIONAL GROUP, INC. ("AIG") AND AGL ENTERED INTO A CONSENT ORDER WITH NYSDFS FINDING THAT AGL HAD CONDUCTED AN INSURANCE BUSINESS IN NEW YORK WITHOUT A NEW YORK LICENSE IN CONNECTION WITH ITS PENSION RISK TRANSFER ("PRT") BUSINESS, IN VIOLATION OF INSURANCE LAW § 1102(A). Status: Final Sanction Detail: PURSUANT TO THE ORDER, AGL WILL ALSO TAKE AGREED-UPON ACTIONS WITH RESPECT TO NY-BASED PARTICIPANTS IN LEGACY AND FUTURE PRT TRANSACTIONS TO ENSURE ACTIVITIES IN NY ARE APPROPRIATELY LICENSED AND IN COMPLIANCE WITH NY LAW. AGL MUST SUBMIT ANNUAL AFFIDAVITS OF COMPLIANCE WITH THE TERMS OF THE ORDER FOR A PERIOD OF 3 YEARS. AGL PAID THE $12,000,000 CIVIL PENALTY ON 02/05/2021. Summary: THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Allegations: ON APRIL 27, 2022, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $2,000.00 VOLUNTARY FORFEITURE AS A RESULT OF A MARKET CONDUCT INVESTIGATION. THE DIVISION ALLEGED THAT THE COMPANY 1) FAILED TO RETAIN COPIES OF THE CERTIFICATE APPLICATIONS, GROUP POLICY(IES), GROUP POLICY FORM NUMBER, EMPLOYER NAME(S), AND RECORD OF TERMINATION DATE(S) OF THE GROUP(S) INFORCE SPECIFIED DISEASE CERTIFICATES, AND 2) MISREPRESENTED BY OMISSION THE BENEFITS, ADVANTAGES, CONDITIONS, AND TERMS OF THE GROUP POLICY AND SPECIFIED DISEASE CERTIFICATE WHEN THE COMPANY DID NOT NOTIFY CERTIFICATE HOLDERS OF THE TERMINATION OF COVERAGE AFTER THE GROUP MASTER POLICY WAS CANCELLED/TERMINATED. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $2,000.00 ON 4/27/2022. THE FULL AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED. Summary: ON APRIL 27, 2022, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $2,000.00 VOLUNTARY FORFEITURE AS A RESULT OF A MARKET CONDUCT INVESTIGATION. THE DIVISION ALLEGED THAT THE COMPANY 1) FAILED TO RETAIN COPIES OF THE CERTIFICATE APPLICATIONS, GROUP POLICY(IES), GROUP POLICY FORM NUMBER, EMPLOYER NAME(S), AND RECORD OF TERMINATION DATE(S) OF THE GROUP(S) INFORCE SPECIFIED DISEASE CERTIFICATES, AND 2) MISREPRESENTED BY OMISSION THE BENEFITS, ADVANTAGES, CONDITIONS, AND TERMS OF THE GROUP POLICY AND SPECIFIED DISEASE CERTIFICATE WHEN THE COMPANY DID NOT NOTIFY CERTIFICATE HOLDERS OF THE TERMINATION OF COVERAGE AFTER THE GROUP MASTER POLICY WAS CANCELLED/TERMINATED. THE COMPANY AGREED TO THE FOLLOWING REMEDIAL ACTION: FILE AN AMENDMENT TO THE GROUP CERTIFICATE STATING AMERICAN GENERAL WILL NOT CANCEL THE CERTIFICATES OR MAKE COVERAGE DETERMINATIONS EXCEPT BASED ON PROVISIONS IN THE CERTIFICATE; PROVIDE THE 10 INFORCE CERTIFICATE HOLDERS THE OPTION TO CONTINUE COVERAGE OR BE ISSUED A REFUND BACK TO DECEMBER 31, 2012, LESS BENEFITS RECEIVED; AND MAINTAIN BUSINESS RECORDS IN ACCORDANCE WITH APPLICABLE LAW.

Allegations: IN DECEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $10,000.00 ADMINISTRATIVE FINE TO THE OFFICE OF THE INSURANCE COMMISSIONER FOR THE STATE OF WASHINGTON BASED ON THE COMMISSIONER'S FINDING THAT THE COMPANY ALLEGEDLY ACCEPTED APPLICATIONS IN 2019 AND 2020 FROM PRODUCERS WHO DID NOT COMPLETE THE STATE'S REQUIRED ANNUITY SUITABILITY TRAINING. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $10,000.00 PAID ON 12/03/2021. THE FULL FINE AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED. Summary: IN DECEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $10,000.00 ADMINISTRATIVE FINE TO THE OFFICE OF THE INSURANCE COMMISSIONER FOR THE STATE OF WASHINGTON BASED ON THE COMMISSIONER'S FINDING THAT THE COMPANY ALLEGEDLY ACCEPTED APPLICATIONS IN 2019 AND 2020 FROM PRODUCERS WHO DID NOT COMPLETE THE STATE'S REQUIRED ANNUITY SUITABILITY TRAINING.

Allegations: ON DECEMBER 26, 2023, THE UNITED STATES LIFE INSURANCE COMPANY IN THE CITY OF NEW YORK PAID A $5,146,245.00 CIVIL PENALTY TO THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANY'S INDIVIDUAL LIFE, INDIVIDUAL ANNUITY AND GROUP INSURANCE BUSINESSES COVERING THE TIME PERIOD OF JANUARY 1, 2012 THROUGH DECEMBER 31, 2016. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $5,146,245.00 PAID ON DECEMBER 26, 2023. THE FULL AMOUNT WAS LEVIED AGAINST THE UNITED STATES LIFE INSURANCE COMPANY IN THE CITY OF NEW YORK WITH NO PORTION OF THE FINE WAIVED. Summary: ON DECEMBER 26, 2023, THE UNITED STATES LIFE INSURANCE COMPANY IN THE CITY OF NEW YORK PAID A $5,146,245.00 CIVIL PENALTY TO THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANY'S INDIVIDUAL LIFE, INDIVIDUAL ANNUITY AND GROUP INSURANCE BUSINESSES COVERING THE TIME PERIOD OF JANUARY 1, 2012 THROUGH DECEMBER 31, 2016.

Allegations: ON AUGUST 3, 2023, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $160,000 VOLUNTARY FORFEITURE TO THE INSURANCE DEPARTMENT OF THE COMMONWEALTH OF PENNSYLVANIA TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANY'S INDIVIDUAL LIFE, INDIVIDUAL ANNUITY, AND GROUP ANNUITY BUSINESSES COVERING THE TIME PERIOD OF JANUARY 1, 2021 THROUGH DECEMBER 31, 2021. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $160,000 PAID ON AUGUST 3, 2023. THE FULL AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED. Summary: ON AUGUST 3, 2023, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $160,000 VOLUNTARY FORFEITURE TO THE INSURANCE DEPARTMENT OF THE COMMONWEALTH OF PENNSYLVANIA TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANY'S INDIVIDUAL LIFE, INDIVIDUAL ANNUITY, AND GROUP ANNUITY BUSINESSES COVERING THE TIME PERIOD OF JANUARY 1, 2021 THROUGH DECEMBER 31, 2021.

Allegations: ON MARCH 30, 2024, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID AN ADMINISTRATIVE PENALTY OF $2,500.00 TO THE NEW HAMPSHIRE INSURANCE DEPARTMENT TO RESOLVE ALLEGED VIOLATIONS THAT THE COMPANY VIOLATED NH RSA 400-A:16, II BY FAILING TO RESPOND WITHIN 10 WORKING DAYS TO THE NHID'S JANUARY 10, 2024 REQUEST AND BY FAILING TO RESPOND WITHIN 10 WORKING DAYS TO THE NHID'S JANUARY 30, 2024 REQUEST. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $2,500 PAID ON MARCH 30, 2024. THE FULL AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED. Summary: ON MARCH 30, 2024, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID AN ADMINISTRATIVE PENALTY OF $2,500.00 TO THE NEW HAMPSHIRE INSURANCE DEPARTMENT TO RESOLVE ALLEGED VIOLATIONS THAT THE COMPANY VIOLATED NH RSA 400-A:16, II BY FAILING TO RESPOND WITHIN 10 WORKING DAYS TO THE NHID'S JANUARY 10, 2024 REQUEST AND BY FAILING TO RESPOND WITHIN 10 WORKING DAYS TO THE NHID'S JANUARY 30, 2024 REQUEST.

Allegations: IN SEPTEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $32,250.00 ADMINISTRATIVE FINE TO THE MARYLAND INSURANCE ADMINISTRATION TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S ROUTINE MARKET CONDUCT EXAMINATION OF THE COMPANY'S INDIVIDUAL LIFE INSURANCE BUSINESS, COVERING THE TIME PERIOD OF JUNE 1, 2018 THROUGH JANUARY 31, 2020. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $32,250.00 PAID ON 09/23/2021. THE FULL FINE AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED. Summary: IN SEPTEMBER 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $32,250.00 ADMINISTRATIVE FINE TO THE MARYLAND INSURANCE ADMINISTRATION TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S ROUTINE MARKET CONDUCT EXAMINATION OF THE COMPANY'S INDIVIDUAL LIFE INSURANCE BUSINESS, COVERING THE TIME PERIOD OF JUNE 1, 2018 THROUGH JANUARY 31, 2020.

Allegations: IN AUGUST 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $106,000.00 ADMINISTRATIVE FINE TO THE DELAWARE DEPARTMENT OF INSURANCE TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S ROUTINE MARKET CONDUCT EXAMINATION OF THE COMPANY'S INDIVIDUAL LIFE AND INDIVIDUAL ANNUITY BUSINESSES. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $106,000.00 PAID ON 8/11/2021. FULL AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED. Summary: IN AUGUST 2021, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $106,000.00 ADMINISTRATIVE FINE TO THE DELAWARE DEPARTMENT OF INSURANCE TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S ROUTINE MARKET CONDUCT EXAMINATION OF THE COMPANY'S INDIVIDUAL LIFE AND INDIVIDUAL ANNUITY BUSINESSES.

Allegations: IN JUNE 2022, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $117,300.00 VOLUNTARY FORFEITURE TO THE MISSOURI STATE SCHOOL FUND TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANY'S LIFE AND ACCIDENT & HEALTH BUSINESS, COVERING THE TIME PERIOD JANUARY 1, 2014 THROUGH DECEMBER 31, 2017. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $117,300.00 PAID ON 6/3/2022. THE FULL FORFEITURE AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED. Summary: IN JUNE 2022, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $117,300.00 VOLUNTARY FORFEITURE TO THE MISSOURI STATE SCHOOL FUND TO RESOLVE ALLEGED VIOLATIONS ARISING OUT OF THE STATE'S MARKET CONDUCT EXAMINATION OF THE COMPANY'S LIFE AND ACCIDENT & HEALTH BUSINESS, COVERING THE TIME PERIOD JANUARY 1, 2014 THROUGH DECEMBER 31, 2017.

Allegations: ON OCTOBER 2, 2024, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $13,500 VOLUNTARY FORFEITURE, $12,500 IN FINES AND $1,000 IN ADMINISTRATIVE COST, TO THE FLORIDA OFFICE OF FINANCIAL REGULATION TO RESOLVE THE DEPARTMENT'S FINDING OF A VIOLATION OF 627.9175(1) AND RULE 69O-137.004 FOR FAILURE TO TIMELY FILE FORM OIR-B2-1094, "REPORT OF GROSS ANNUAL PREMIUMS AND ENROLLMENT DATA FOR HEALTH BENEFIT PLANS ISSUED TO FLORIDA RESIDENTS", WITH THE OIR COVERING THE PRECEDING CALENDAR YEAR ON OR BEFORE APRIL 1, 2024. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $13,500 PAID ON OCTOBER 2, 2024. THE FULL AMOUNT WAS LEVIED AGAINST AMERICAN GENERAL LIFE INSURANCE COMPANY WITH NO PORTION OF THE FINE WAIVED. Summary: ON OCTOBER 2, 2024, AMERICAN GENERAL LIFE INSURANCE COMPANY PAID A $13,500 VOLUNTARY FORFEITURE, $12,500 IN FINES AND $1,000 IN ADMINISTRATIVE COST, TO THE FLORIDA OFFICE OF FINANCIAL REGULATION TO RESOLVE THE DEPARTMENT'S FINDING OF A VIOLATION OF 627.9175(1) AND RULE 69O-137.004 FOR FAILURE TO TIMELY FILE FORM OIR-B2-1094, "REPORT OF GROSS ANNUAL PREMIUMS AND ENROLLMENT DATA FOR HEALTH BENEFIT PLANS ISSUED TO FLORIDA RESIDENTS", WITH THE OIR COVERING THE PRECEDING CALENDAR YEAR ON OR BEFORE APRIL 1, 2024.

Allegations: ON OCTOBER 8, 2024, THE UNITED STATES LIFE INSURANCE COMPANY IN THE CITY OF NEW YORK PAID A $13,500 VOLUNTARY FORFEITURE, $12,500 IN FINES AND $1,000 IN ADMINISTRATIVE COST, TO THE FLORIDA OFFICE OF FINANCIAL REGULATION TO RESOLVE THE DEPARTMENT'S FINDING OF A VIOLATION OF 627.9175(1) AND RULE 69O-137.004 FOR FAILURE TO TIMELY FILE FORM OIR-B2-1094, "REPORT OF GROSS ANNUAL COMPANY DISCOVERED THE BREACH OR THE DATE THE COMPANY PROVIDES PREMIUMS AND ENROLLMENT DATA FOR HEALTH BENEFIT PLANS ISSUED TO FLORIDA RESIDENTS", WITH THE OIR COVERING THE PRECEDING CALENDAR YEAR ON OR BEFORE APRIL 1, 2024. Status: Final Sanction Detail: TOTAL AMOUNT PAID: $13,500 PAID ON OCTOBER 8, 2024. THE FULL AMOUNT WAS LEVIED AGAINST THE UNITED STATES LIFE INSURANCE COMPANY IN THE CITY OF NEW YORK WITH NO PORTION OF THE FINE WAIVED. Summary: ON OCTOBER 8, 2024, THE UNITED STATES LIFE INSURANCE COMPANY IN THE CITY OF NEW YORK PAID A $13,500 VOLUNTARY FORFEITURE, $12,500 IN FINES AND $1,000 IN ADMINISTRATIVE COST, TO THE FLORIDA OFFICE OF FINANCIAL REGULATION TO RESOLVE THE DEPARTMENT'S FINDING OF A VIOLATION OF 627.9175(1) AND RULE 69O-137.004 FOR FAILURE TO TIMELY FILE FORM OIR-B2-1094, "REPORT OF GROSS ANNUAL PREMIUMS AND ENROLLMENT DATA FOR HEALTH BENEFIT PLANS ISSUED TO FLORIDA RESIDENTS", WITH THE OIR COVERING THE PRECEDING CALENDAR YEAR ON OR BEFORE APRIL 1, 2024.